Shenzhen Topband Co., Ltd. Information Disclosure Management System (Draft) (Applicable after H-share issuance and listing)
Chapter 1 General Provisions
Article 1 To regulate the information disclosure activities of Shenzhen Topband Co., Ltd. (hereinafter referred to as the "Company"), strengthen the management of information disclosure affairs, ensure the fairness of information disclosure, and protect the legitimate rights and interests of investors, in accordance with the "Company Law of the People's Republic of China," the "Securities Law of the People's Republic of China" (hereinafter referred to as the "Securities Law"), the "Administrative Measures for Information Disclosure by Listed Companies," the "Shenzhen Stock Exchange GEM Stock Listing Rules" (hereinafter referred to as the "SZSE Listing Rules"), the Hong Kong Laws Chapter 571 "Securities and Futures Ordinance" of Hong Kong, the "Rules Governing the Listing of Securities on The Stock Exchange of Hong Kong Limited" (hereinafter referred to as the "HKEX Listing Rules"), other relevant laws and regulations, and the "Articles of Association," and combined with the actual situation of the Company, this System (hereinafter referred to as the "System") is hereby formulated.
Article 2 This System shall be binding on the Company's shareholders, directors, senior management, all departments of the Company, and all subsidiaries.
Chapter 2 Basic Principles of Information Disclosure
Article 3 "Information" as referred to in this System means material information that may have a significant impact on the trading price of the Company's securities and their derivatives and is not yet known to investors.
Article 4 The Company and relevant information disclosure obligors shall disclose information truthfully, accurately, completely, and timely, in a concise, clear, and easy-to-understand manner, and shall not contain any false records, misleading statements, or major omissions. The information disclosed by the Company and information disclosure obligors shall be disclosed to all investors simultaneously and shall not be disclosed in advance to any unit or individual. However, this shall not apply where laws or administrative regulations provide otherwise. Given that the Company is listed on both the Shenzhen Stock Exchange and overseas securities markets, information disclosed by the Company and relevant information disclosure obligors on overseas stock exchanges shall also be disclosed in accordance with the relevant regulations of the China Securities Regulatory Commission and the Shenzhen Stock Exchange in media that meet the conditions.
Information Disclosure Management System
When the Company and relevant information disclosure obligors disclose information in overseas markets, if it is outside the information disclosure hours of the Shenzhen Stock Exchange, it shall be disclosed during the nearest information disclosure period of the Shenzhen Stock Exchange. The reports and announcements provided by the Company and relevant information disclosure obligors to overseas stock exchanges on the same matter shall be consistent with the content provided to the Shenzhen Stock Exchange. In case of significant discrepancies, the Company and relevant information disclosure obligors shall make a special explanation to the Shenzhen Stock Exchange and disclose a correction or supplementary announcement. According to the "HKEX Listing Rules," all announcements, circulars, and other documents disclosed by the Company on the designated website of the Hong Kong Stock Exchange, "www.hkexnews.hk," shall also be published on the Company's official website.
Article 5 Continuous information disclosure is the responsibility of the Company and relevant information disclosure obligors. The Company and its directors and senior management shall faithfully and diligently perform their duties to ensure the truthfulness, accuracy, completeness, timeliness, and fairness of the disclosed information.